--- title: "Carbonaide's feedback on how to strengthen the EU ETS to deliver on industry decarbonisation goals and CDR" date: 2026-10-28T08:29:54Z modified: 2026-10-28T08:30:10Z permalink: "https://carbonaide.com/blogs/carbonaides-feedback-on-how-to-strengthen-the-eu-ets-to-deliver-on-industry-decarbonisation-goals-and-cdr/" type: post status: publish excerpt: The EU ETS revision offers an opportunity to increase ambition in industry decarbonisation and CDR. wpid: 11904 categories: - Blogs language: - English featured_image: "https://carbonaide.com/wp-content/uploads/2026/10/guillaume-perigois-0nrkvdda2fw-unsplash-scaled.jpg" timestamp: 2026-10-28T08:30:10Z tags: - Blogs - English --- EU ETS will have an important role in scaling decarbonisation technologies and having meaningful contribution to reaching the Paris-aligned temperature goals by the end of the century. UNEP’s 2026 Emission Gap report confirms the gap is widening with every year of insufficient action and redefines what it takes to stay on track. The contrast between what we need to do and the reality is stark. We need immediate and rapid emission reductions: 18 percent by 2030, 45 percent by 2035, and 69 percent by 2040, relative to 2025 levels. NDCs are insufficient, putting us on track to 2.6°C. In addition, durable carbon removal must scale to 320 GtCO₂ by 2100, up from 2 MtCO₂ annually today. Instead, we have a historic high of energy supply from coal, oil and gas. The report says current policies will trigger a peak and decline in coal before 2030, but oil and gas use will likely keep increasing this decade. Fit-for-purpose climate policies are critical for accelerating industry decarbonisation. EU ETS revision is one such opportunity. Stakeholders can [provide feedback](https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14549-EU-emissions-trading-system-for-maritime-aviation-and-stationary-installations-and-market-stability-reserve-review_en) on the EU ETS revision proposal by November 3, 2026. ![](https://carbonaide.com/wp-content/uploads/2026/10/wolfgang-weiser-23brp1we8n0-unsplash-scaled.jpg) ## Scaling durable carbon removal Carbnaide welcomes the Commission’s 17 July proposal, which would create the world’s first compliance market for permanent CDR at scale. As a member of the Nordic Carbon Removal Association, Carbonaide support’s NCRA position on scaling CDR. To deliver on it, we ask co-legislators to strengthen the text in the following ways: 1. ****Make the 250 Mt target explicit.**** Article 9c should state that the ETS shall deliver 250 Mt of domestic permanent removals by 2040, with purchases frontloaded through offtake agreements and payment on delivery. Procurement rules should be adopted urgently, with first offtakes by 2029, so removals can flow from 2031. 2. ****Secure dedicated funding.**** The Commission should commit sufficient resources for the full volume, and projects should be able to combine ETS funding sources: allowance revenues, Member State funding, the Innovation Fund, and priority access to the Industrial Decarbonization Bank and Investment Booster. The 10 million allowances should be increased significantly to cover the shortfall in auction revenues, to at least 60 million allowances subject to review in the mid-2030s. 3. **Allow sales of self-generated removals.** Under Article 14, operators that generate permanent removals, such as waste-to-energy plants with capture, should be able to sell them to other ETS operators, without double counting. Operators could meet up to 1% of their ETS obligations through direct purchases from domestic suppliers supported by the Innovation Fund or the EU Buyer’s Club. Procurement on the secondary market should also be explored. 4. ****Open a pathway for additional durable CDR methods and completely exclude nature-based removals from the ETS review clause.**** Only bio-CCS and DACCS are eligible today. A new Article 9c(4a) should empower the Commission to set methodology-specific criteria and quotas through delegated acts, reviewed every two years. Criteria should match the integrity and enforceability of geological storage under the CCS Directive, be proportionate to each method’s risk profile, build on approved CRCF methodologies and include liability for reversals. The purchasing program should cover all eligible methods to drive down costs. Regarding international credits, the NCRA finds that domestic removals must take priority. The Commission draft sets international credits in potential competition with European removals while relaxing the cap for credits that may never materialize, creating avoidable uncertainty for developers. Unused allowances set aside for credits should go to domestic removals, and the Commission’s 2033 report should assess the crowding-out risk. The window is narrow: procurement rules and offtakes must be in place by 2029. [ ![](https://carbonaide.com/wp-content/uploads/2026/10/screenshot-2026-10-22-at-11.27.55.png) ](https://wedocs.unep.org/rest/api/core/bitstreams/8819b586-8d60-4aaf-bd0e-4a48d04759f2/content) Global GHG scenarios, UNEP Emission Gap Report 2026 ## Accelerating industry decarbonisation The EU ETS revision offers an opportunity to increase ambition in industry decarbonisation and CDR. 2026 Emissions Gap report underlines that, to stay within Paris-aligned long-term temperature goals, we need to limit peak warming to 1.7-1.8°C with a 66 percent chance and return to or below 1.5°C by 2100 with around a 50 percent chance. This will require reducing GHG emissions by 18 percent by 2030, 45 percent by 2035, and 69 percent by 2040, relative to 2025 levels. The report estimates that roughly 320 GtCO₂ of durable carbon removal is needed to return warming to 1.5°C by 2100. 1. **Accelerating decarbonisation technology adoption.** Many innovative low-carbon technologies are already commercially available but struggle to compete with conventional products. The EU ETS revision is an opportunity to deliver rapid emission reductions from hard-to-abate sectors. However, the proposal delays decarbonisation by slowing cap reductions after 2030, pushing ETS net-zero from 2040 to 2048 and extending free allowances from 2034 to 2038. While the goal is to help industries stay competitive amid high energy prices, this risks slowing the green transition by delaying uptake of decarbonisation technologies already available today. 2. **Supporting less mature CDR methods.** The EU should support less mature CDR methods, not yet approved under the EU CRCF, by creating a distinct track (e.g., pre-certification status) that doesn’t generate tradable credits but sends a clear signal about future inclusion. 3. **Adopting a technology-neutral approach.** A narrow scope of eligible technologies for funding opportunities under the upcoming Industrial Decarbonisation Bank, the Investment Booster, and the EU Carbon Removal and Carbon Farming Regulation risks leaving many solutions on the sidelines. We need all the help we can get from proven, scalable solutions to return from the overshoot and drive temperatures back down. 4. **Treating mineralisation of CO₂ in concrete equally.** Under the EU ETS, chemically bound CO₂ is considered equivalent to geological storage, but there is no clear timeline for its inclusion under the EU CRCF. The latest analysis indicates that global construction activity is forecast to grow by more than 70% by 2050, reaching US$16.6 trillion, according to a new report by Oxford Economics. Excluding CO₂ mineralization in concrete is a huge, untapped opportunity to transform the construction industry into a carbon sink. For instance, if adopted globally, Carbonaide technology could create a 1.6 Gt annual carbon dioxide sink. At the same time, the technology reduces concrete emissions by reducing cement use. ![](https://carbonaide.com/wp-content/uploads/2026/10/carbonaide_fullres-ristotakala-4587-scaled.jpg) ![](https://carbonaide.com/wp-content/uploads/2025/08/cropped-carbonaide-favicon.png) Read more about the Carbonaide Credits: [ Discover Carbonaide Credits ](https://carbonaide.com/wp-content/uploads/wp-mfa-exports/page/carbonaide-credits.md)